Loading...
HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 029 - Plaintiff's Unopposed Motion For Extension Of Time To File Pre-Trial MotionsDISTRICT COURT, LARIMER COUNTY, STATE OF COLORADO Court Address: 201 Laporte Ave. Fort Collins, CO 80621 Plaintiffs: STUWARD CROSS AND KATRINA RICHMAN v. Defendant: THE CITY OF FORT COLLINS, STATE OF COLORADO Court Use Only Attorneys for Plaintiffs: Laura Browne, # 46673 WILHITE, ROSE, MCCLURE & SAWAYA, P.C. 1600 Ogden Street Denver, CO 80218 Phone Number: (303) 839-1650 FAX Number: (303) 832-7102 E-mail: lbrowne@sawayalaw.com Case Number: 2020CV30363 Division: 5A PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL MOTIONS COME NOW, Plaintiffs by and through their attorneys of record Wilhite, Rose, McClure, and Sawaya, hereby submit their Unopposed Motion for Extension of Time to file Pretrial Motions, state the following: C.R.C.P. 121 CONFERRAL Counsel for Plaintiffs conferred with counsel for the Defendant. This Motion is unopposed. BACKGROUND 1. Plaintiffs filed their Complaint on May 29, 2020. 2. A five-day trial in this matter is scheduled to begin November 15, 2021. 3. The deadline for the parties to file pretrial motions is October 4, 2021. DATE FILED: October 1, 2021 1:03 PM FILING ID: CFE6E0607E543 CASE NUMBER: 2020CV30363 2 4. Plaintiff requests a one-week extension of time to file pretrial motions. 5. Counsel for Defendant does not oppose this Motion. 6. No party will be prejudiced by the one-week extension of time to file pretrial motions. 7. The requested extension of time will not affect the parties ability to prepare for trial and no parties are requesting to continue the trial date. CONCLUSION WHEREFORE, Plaintiffs respectfully requests this Court GRANT Plaintiffs’ Unopposed Motion for Extension of Time to File Pretrial Motions through October 11, 2021. DATED: October 1, 2021. Respectfully submitted, WILHITE, ROSE, MCCLURE & SAWAYA, P.C. /s/ Laura Browne Original Signature on File in Attorney’s Office Laura Browne, Attorney for Plaintiff 3 CERTIFICATE OF SERVICE I hereby certify that on October 1, 2021 this PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL MOTIONS was filed and served via CCEF addressed to the following counsel of record: Andrew W. Callahan, Esq. WICK & TRAUTWEIN, LLC P.O. Box 2166 Fort Collins, CO 80522 Attorney for Defendant Adam Stephens, Esq. FORT COLLINS CITY ATTORNEY’S OFFICE P.O. Box 580 Fort Collins, CO 80522 Attorney for Defendant /s/ Kassandra Burival Original Signature on File in Attorney’s Office Kassandra Burival, Litigation Paralegal